A person is not guilty of an offence under section 106B, 106C or 106D if the capacity in which the person is required to give the notice or make and deliver the return is—
(a) as a relevant trustee of a settlement, or
(b) as the executor or administrator of a deceased person.
The Treasury may by regulations provide that a person is not guilty of an offence under section 106B, 106C or 106D if—
(a) conditions specified in the regulations are met, or
(b) circumstances so specified exist.
The conditions may (in particular) include conditions in relation to the income, assets or activities on or by reference to which the tax in question is chargeable.